A. Firm Information
Kennedy Investment Group, Inc. (“KIG” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State of New Jersey.
KIG was founded in October 2003 and is owned and operated by John W. Kennedy III (President and CEO). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by KIG.
B. Advisory Services Offered
KIG offers investment advisory services to individuals, high net worth individuals, and retirement plans (each referred
to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. KIG's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Wealth Management Services
KIG provides tailored investment advisory solutions to its Clients. This is achieved through personal Client contact
and interaction while providing a broad range of comprehensive financial planning and discretionary investment
management over Client portfolios. These services are described below.
Financial Planning Services – KIG provides a variety of financial planning services to Clients. Financial planning
services involve preparing a formal financial plan, which encompass one or more areas of need including but not
limited to investment planning, retirement planning, education planning, estate planning, tax planning, insurance
planning, and other areas of a Client’s financial situation. KIG will work closely with each Client to understand their
financial situation, investment goals, objectives, and overall risk tolerance. A financial plan developed for the Client
will include general recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their portfolio or asset allocation strategy, commence,
or alter retirement savings, and/or establish education savings. KIG may also refer Clients to an accountant, attorney,
or other specialists, as appropriate for their unique situation. Financial planning recommendations pose a conflict
between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to
recommend that Clients engage the Advisor for investment management services or to increase the level of
investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are
not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the
Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no
obligation to implement the transaction through the Advisor.
Investment Management Services - KIG provides customized discretionary investment management services to its
Clients. KIG works closely with each Client to create a portfolio strategy based on their investment goals, objectives,
and risk tolerance. KIG will construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or
exchange-traded funds (“ETFs”), individual stocks, bonds, options contracts, and alternative investments to meet the
needs of its Clients. The Advisor may retain other types of securities from a Client’s legacy investments based on
portfolio fit and/or tax considerations.
KIG’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. KIG will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
KIG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. KIG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. KIG may
recommend specific positions
to increase sector or asset class weightings. The Advisor may recommend employing
cash positions as a possible hedge against market movement. KIG may recommend selling positions for reasons
that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance
of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will KIG accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such
a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as
a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed
by the Advisor.
Use of Independent Managers - KIG may recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize
and enter into an investment management agreement with the Independent Manager[s] that defines the terms in
which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and
due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial portfolio
recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with
an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure
(or a brochure that makes the appropriate disclosures).
C. Client Account Management
Prior to engaging KIG to provide investment advisory services, each Client is required to enter into an agreement
with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These
services may include:
• Establishing an Investment Strategy – KIG, in connection with the Client, will develop a portfolio strategy that
seeks to achieve the Client’s investment goals, time horizon, financial situation, and risk tolerance for each
Client.
• Investment Management and Supervision – KIG will provide investment management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
KIG includes securities transaction fees together with its wealth management fees. Including these fees into a single
asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its wealth management services for
its Clients. The Advisor sponsors the KIG Financial Wrap Fee Program solely as a supplemental disclosure regarding
the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the
Client may pay more or less in total fees than if the Client paid its own securities transaction fees. Please see
Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2022, KIG manages $397,444,659 in Client assets, all of which are managed on a discretionary
basis. Clients may request more current information at any time by contacting the Advisor.